PN047 - Vulnerable Groups Privacy Notice

Torfaen County Borough Council is committed to protecting your privacy when you use our services. This Privacy Notice is designed to give you information about the data we hold about you, how we use it, your rights in relation to it and the safeguards in place to protect it.

TCBC Service Area: Children and Family Services
Work area: Additional Learning Needs (ALN)
Contact Details: Donna Lewis
Privacy Notice Name: ALN – Vulnerable Groups i.e. Gypsy Roma Traveller; English as an additional language; Young Carers; Pregnant Teenagers; Families in difficult circumstances; those educated other than at school; pupils on modified days

Data Controller: Torfaen County Borough Council, c/o Civic Centre, Pontypool, NP4 6YB

If you wish to raise a concern about the handling of your personal data, please contact the Data Protection Officer on 01495 762200 or email

The Education Service has to monitor the education provision for all vulnerable pupils and have requirements to collect data on individual groups as subscribed by the Welsh Government and Estyn.

Who provides your data to the Council?

We receive personal information indirectly from:

  • Schools
  • Pupil Admissions Forms
  • Social Care
  • Data returns e.g. Pupil Level Annual School Census
  • Gwent Education Minority Ethnic Service (GEMS)

How does the Council collect this information?

  • Electronic transfer of data between School and Local Authority (LA systems)
  • Admissions forms added onto LA Capita ONE system
  • Social Care and GEMS pupil lists provided termly

What information does the Council collect about you?

The ALN Team collects:

  • Name
  • Date of Birth
  • National Curriculum Year
  • Address of young person
  • Age
  • Parent’s names
  • Parents/carer contact details
  • School/education provision name
  • Education Information
  • Additional Learning Needs Status
  • Looked After/legal Status
  • Attendance data
  • Attainment /Assessment data
  • Exclusion data
  • Other agencies involved
  • Gender
  • Home Language

Why does the Council process your personal data?

Under Article 6 of the UK General Data Protection Regulation (GDPR), the lawful basis we rely on for processing this information is:

(e) We need it to perform a public task.

The education service has to monitor the education provision for all vulnerable pupils and have requirements to collect data on individual groups as subscribed by the Welsh Government and Estyn.

Special categories of personal data:

We collect the following special category data:

  • personal data revealing racial or ethnic origin
  • personal data revealing religious or philosophical beliefs

We collect this under Article 9 of the UK GDPR.

We do not collect criminal data

Who has access to your data?

Your data is shared internally only with the appropriate staff where it is necessary for the performance of their roles.

No pupil level data is shared with outside agencies

Apart from where previously stated, we do not pass your details to third parties unless we are lawfully required do so.

Is the Data transferred out of the UK?


How does the Council keep your data secure?

The Council has internal policies in place to ensure the data it processes is not lost, accidentally destroyed, misused or disclosed. Access to this data is restricted in accordance with the Council’s internal policies and in compliance with the UK GDPR.

Data will be stored securely in:

  • Secure pupil files on the Council’s education directory on a secure drive
  • Via the Capita ONE secure database

How long does the Council keep your data?

The Council will hold your personal data only for the period that is necessary and will follow organisational and Local Authority standards in this area. At the end of the retention period the Council will securely destroy or dispose of the data in line with retention schedules.

  • The ALN Service retain records in line with the Council policy of date of birth + 25 years

Are we making automated decisions/profiling with your data?


Your rights

You have a number of Rights you can exercise:

  • Access - to obtain a copy of your data on request
  • Rectification – to require the Council to change incorrect or incomplete data
  • Object, Restrict or Delete - under certain circumstances you can require the Council to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing
  • Data portability – to receive and/or transmit data provided to the Council to other organisations (this applies in limited circumstances))
  • Withdraw your consent at any time (where consent has been given)
  • To know the consequences of failing to provide data to the Council
  • To know the existence of any Automated Decision-making, including profiling, and the consequences of this for you.
  • To lodge a complaint with a supervisory authority (Information Commissioners Office)

If you would like to exercise any of these rights, please contact Donna Lewis Senior ALN Manager 01495 766974

The Information Commissioner can be contacted at: The Information Commissioner’s Office (Wales), 2nd Floor, Churchill House, Churchill Way, Cardiff, CF10 2HH. Telephone 0330 414 6421 or e-mail

Last Modified: 04/10/2023 Back to top